Plaintiffs' First Request to Produce to Defendant Methodist Hospital of Gary, Inc.

     [||91c9911e-103d-4838-a610-9b50bef9c4f9||] September 21, 1977 

Hon. Francis T. Grandys, Clerk 

United States District Court 

Northern District of Indiana 

Hammond Division 

Federal Building, 502 State Street 

Hammond, Indiana 46325 

Re: Bernice Terry, et al. v. Methodist Hospital 

of gary, Inc,, et al,, No. H 76-373. 
  

Richard Gordon Hatcher, et al. v. Methodist 

Hospital of Gary, Inc., et al., No. H 77- 

154. 
  

Dear Mr. Grandys: 

Enclosed are two copies of Plaintiffs' First Re- 

quest To Produce to Defendant Methodist Hospital 
of ‘gary, Inc., for filing. 

Thank you for your consideration. 

Sincerely yours, 

5 F 7 $3 0 Fe J 

A I. 2 OE 7 . > L. Fa 

i § v 

Beth J. Lief 

Attorney for Plaintiffs 

JL/x 

Enclosures #2 

  

IC COLUMBUS CIRCLE 58686-8397 NEWSY ORK, N.Y. 10019 

 



  

IN THE 

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

  

BERNICE TERRY, et al., 

  

  

Plaintiffs, : 

V. : NO, H 76-373 

METHODIST HOSPITAL OF GARY, INC., ! 

et. al.y, : 

Defendants. : 

RICHARD GORDON HATCHER, et al., : 

Plaintiffs, : 

Vs NO. H 77-154 

METHODIST HOSPITAL OF GARY, INC., : 

et-al., 2 

Defendants. 

  

PLAINTIFFS' FIRST REQUEST TO PRODUCE TO 
DEFENDANT METHODIST HOSPITAL OF GARY, INC 

Pursuant to Rule 34 of the Federal Rules of Civil Procedure, 

plaintiffs request that defendant Methodist Hospital of Gary, Inc., 

and its agents and employees (hereinafter "Methodist Hospital"), 

make available for inspection and photocopying at a place and time 

mutually convenient for parties the following: 

1. All minutes of the Board of Directors of Methodist 

Hospital from 1963 to the present. 

2. All architectural plans, diagrams, charts and other re- 

cords of Gary Methodist Hospital and Broadway Methodist Hospital       
 



  

  

  
  

  

from 1923 to the present, including proposed projects, actual 

projects, renovations, remodelings, ward and patient room diagrams, 

and comprehensive hospital layouts. 

3. All records and documents, including but not limited to 

correspondence, pamphlets, newsletters, advertisements, ptoclures,] 

plans both addressed to or intended for the public and not ad- 

dressed to or intended for the public, concerning all fund-raising 

campaigns of Methodist Hospital which were conducted on its own | 

behalf or in cooperation with any other corporations, facilities, 

associations or individuals. 

4, All records and documents, including but not limited to 

correspondence, memoranda, agreements, plans and notes concerning 

all and any efforts, whether successful or not and whether imple- 

mented or not, concerning any efforts by Methodist Hospital and 

other health facilities, organizations, associations, corporations 

and individuals to coordinate health planning and facilities. 

5. All reports, findings, investigations and reviews by any! 

governmental, regulatory or private agencies, associations or | 

groups, including the Joint Commission on Accreditation of 

Hospitals, the State Board of Health, the Department of the Fire 
{ 

Marshal of the State of Indiana, and the United States Department 
{ 

| 
| 
{ 

of Health, Education and Welfare from 1972 to the present. 

6. All financial and accounting records, books and docu- 

ments of Methodist Hospital, containing information as to cost and. 

financing of all capital expenditures at Broadway Methodist 

Hospital and, ‘since 1972 , at Gary Methodist Hospital. 

7. All studies, reviews, reports, correspondence, notes, 

 



  

  

  

memoranda and other documents considered by Methodist Hospital in | 

its decision to construct Broadway Methodist Hospital. 

8. All studies, reviews, reports, correspondence, notes, 

memoranda and other documents considered by Methodist Hospital in 

its decision to expand Broadway Methodist Hospital. 

9. All studies, reviews, reports, plans, notes, memoranda 

and other documents describing, detailing or otherwise concerning 

Methodist Hospital's long-term and short-term plans from 1960 to 

the present. 

10. All proposals and all correspondence, documents, plans, 

financial statements, notes and other memoranda prepared in con- 

nection with approval for Hill-Burton assistance and § 1122 approvr 
| 
| 

al. 

11. All health studies, plans, reports and reviews concern- 

ing the health needs of Gary and Lake County, Indiana. 

12. All financial statements, reports and documents from 

1970 to present, including half-year reports for 1977. 

13. Documents, records, lists and other records as to 

patient days, from 1973 to present, including total figures and 

breakdowns by service, age, race, address, census tract, treat- 

ment, diagnoses, source of admission and method of payment. 

14. All records, documents, data and reports regarding cost | 

per patient and patient charges at Gary Methodist Hospital and 

Broadway Methodist Hospital. 

Respectfully submitted, 

& { i U_ | AK 

JACK GREENBERG 
MELVYN LEVENTHAL 

BETH J. LIEF 

10 Columbus Circle 

Suite 2030 

New York, New York 10019 

  

“3 

 



  

| JULIAN B. ALLEN 
CHARLES B. MILLER 

2009 Broadway 

Gary, Indiana 46407 

  
MARILYN G. ROSE 

CHRISTINE G. HICKMAN | 

1751 N Street, XN. W. 

Washington, D. C. 20036 

| Attorneys for Plaintiffs 

  

      
  

 



          

Certificate of Service 
  

I hereby certify that a copy of the foregoing 

Plaintiffs' First Request to Produce to Defendant 
  

Methodist Hospital of Gary, Inc., 
  

was served by United States mail, postage prepaid, on 
~ 

the > day of September , 1977, on counsel for 
  

defendants as follows: 

Rebecca L. Ross, Esq. 
Department of Justice 
10th and Pennsylvania Avenue 
Washington D.C. 

Marvin G. Garvin, Esq. and Edward L. Koven, 
Regional Attorney and General Attorney 
Department of Health, Education and Welfare 

300 South Wacker Drive, 18th Floor 
Chicago, Illinois 

Fred W. Grady, Esq. 
Assistant United States Attorney 
Northern District of Indiana 
Federal Building, 502 State Street 
Hammond, Indiana 46325 

Attorneys for Defendant Secretary of Health, 
Education and Welfare 

Hodges, Davis, Gruenberg, Compton & Sayers 

Bruce E. Sayers, Esq. 

5525 Broadway 
Gary, Indiana 46401 

Attorneys for Defendant Methodist Hospital 
of Gary, Inc. 

Theodore L. Sendak, Esq. 

Assistant Attorney General of Indiana 
219 State House 
Indianapolis, Indiana 

Attorneys for State Defendants 

Esq. 

  

 



  
    

Anthony DeBonis, Jr., Esq. 

Joseph E. Costanza, Esq. 

Murphy, McAtee, Murphy & Costanza 
First National Bank Building 
720 W. Chicago Avenue 
East Chicago, Indiana 46312 

Attorneys for Defendant Kipton Kaplan 

JY i NK J ANC ae a 
  

Beth J. Lief 

Counsel for Plaintiffs [||91c9911e-103d-4838-a610-9b50bef9c4f9||]